Roger L. and Geraldine Williams - Page 5

                                         -5-                                          
               Petitioner furnished his own supplies at both the Red Lion             
          and SeaTac Airport.  Petitioner obtained most of his supplies               
          from MacPherson Leather Co. (MacPherson Leather), which was                 
          located in Seattle.  On occasion, petitioner purchased supplies             
          from stores such as K-Mart and Safeway.  Petitioner did not                 
          maintain complete records of all of the supplies that he                    
          purchased.  Petitioner did, however, maintain some records of the           
          supplies that he purchased from MacPherson Leather.                         
               Petitioner paid business expenses both in cash and by check.           
          Petitioner's rent under the Port lease was paid by check "so we             
          have a record of what we pay to the Port."  Of the eight receipts           
          for supplies from MacPherson Leather that are included in the               
          trial record, three definitively disclose payment by check (in              
          the amounts of $20.90, $19.36, and $28.50).                                 
               During 1993, an individual by the name of Willie Hughes (Mr.           
          Hughes) performed various services for petitioner.  These                   
          services included accounting and tax preparation services.  Mr.             
          Hughes also assisted petitioner in obtaining the Port lease.                
          Petitioner paid Mr. Hughes for these services.                              
               On his Schedule C for 1993, petitioner claimed a net loss in           
          the amount of $5,111.  In this regard, petitioner reported gross            
          receipts in the amount of $11,700 and claimed expenses in the               
          amount of $16,811.                                                          
               In the notice of deficiency, respondent disallowed the                 
          following expenses claimed by petitioner on his Schedule C:                 




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011